INTM163050 - UK residents with foreign income or gains: income arising abroad: Branch profits - arm's length principle
As indicated in INTM153080, agreements normally provide that where a UK enterprise has a permanent establishment in the other country, the profits attributed to it should be such profits as it might be expected to make if it were a separate enterprise dealing at arm바카라 사이트™s length with the UK enterprise. Any case where it seems doubtful whether the foreign profits have been computed for the purposes of foreign tax on an acceptable arm바카라 사이트™s length basis should be referred to CSTD Business, Assets & International, Transfer Pricing Team.